Tax Treaty “Neutralization” of Source State Discrimination under the EU Fundamental Freedoms?

Journal
Kofler, G.W.
European Union
Bulletin for International Taxation 2011 (Volume 65), No. 12
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This article considers an issue discussed at the 2011 IFA Congress as to whether or not a source state may retain an apparently discriminatory dividend withholding tax and not eliminate domestic economic double taxation if its second layer of taxation is “neutralized” by the shareholder’s residence state via a treaty credit.